Dr. S. Mohan v. Secretary to the Chancellor, Puducherry Technological University, Puducherry 2026 INSC 100 - UGC Regulations 2018
Constitution of India - Seventh Schedule - Entry 25 of List III - While the State Legislature is competent to enact laws on the subject of education, such legislative power is expressly circumscribed by Entries 63 to 66 32 of List I, and in particular, Entry 66 thereof, which confers exclusive authority upon the Parliament to legislate with respect to the coordination and determination of standards in institutions for higher education. (Para 38) Both the Union and the States have legislative competence over education, including medical education, subject to Entry 66 of List I, which exclusively vests Parliament with the power to determine standards in higher education. While the State may regulate education so long as the field is unoccupied, it cannot, in doing so, impinge upon or dilute the standards prescribed by the Union under Entry 66 of List I. (Para 39) [Context: The Supreme Court upheld the Madras High Court’s judgment that Section 14(5) of the Puducherry Technological University Act, 2019, and the Search-cum-Selection Committee constituted thereunder, are inconsistent with mandatory Regulation 7.3 of the UGC Regulations, 2018, because the Committee neither included a nominee of the UGC Chairman nor excluded persons connected with the University.]
Constitution of India - Article 254 - The doctrine of repugnancy and the concomitant requirement of Presidential assent are attracted only where both the Central and State legislations operate within the Concurrent List. (Para 46)
Case Info
Case name and neutral citation:The case is titled Dr. S. Mohan v. The Secretary to the Chancellor, Puducherry Technological University, Puducherry & Ors. etc. with the neutral citation 2026 INSC 100 and Civil Appeal No(s). 54–55 of 2025 (arising out of SLP (C) No. 4593–4594 of 2024).
Coram: Justice Vikram Nath and Justice Sandeep Mehta (Mehta, J. authors the judgment).
Judgment date:The judgment is dated 30 January 2026 (NEW DELHI; JANUARY 30, 2026).
Caselaws and citations referred:The judgment refers to and discusses, among others:
- Kaiser-I-Hind Pvt. Ltd. & Another v. National Textile Corporation (Maharashtra North) Ltd. & Others, (2002) 8 SCC 182.
- Dr. Preeti Srivastava v. State of M.P., (1999) 7 SCC 120.
- Praneeth K. v. UGC, (2021) 14 SCC 241.
- Gambhirdhan K. Gadhvi v. State of Gujarat, (2022) 5 SCC 179.
- Rajiv Sarin & Another v. State of Uttarakhand & Others, (2011) 8 SCC 708.
- R. Chitralekha v. State of Mysore, (1964) 6 SCR 368.
- Modern Dental College v. State of M.P., (2016) 7 SCC 353.
- T.N. Medical Officers’ Association v. Union of India, (2021) 6 SCC 568.
- Gujarat University, Ahmedabad v. Krishna Ranganath Mudholkar, 1962 SCC OnLine SC 146.
- University of Delhi v. Raj Singh, 1994 Supp (3) SCC 516.
- Gram Panchayat, Jamalpur v. Malwinder Singh, (1985) 3 SCC 661.
- Hoechst Pharmaceuticals Ltd. v. State of Bihar, (1983) 4 SCC 45.
Statutes / laws / regulations referred:The Court refers to and applies:
- Constitution of India, particularly Articles 136, 142, 246, 254 and the Seventh Schedule (Entries 25 of List III, 63–66 of List I, and 66 of List I in particular).
- Puducherry Technological University Act, 2019 (PTU Act), especially Section 14 and Section 14(5) and its proviso.
- University Grants Commission Act, 1956 (UGC Act), particularly Sections 14, 26(1)(e) and 26(1)(g).
- UGC Regulations on Minimum Qualifications for Appointment of Teachers and other Academic Staff in Universities and Colleges and Measures for the Maintenance of Standards in Higher Education, 2018(UGC Regulations, 2018), especially Regulation 7.3 concerning appointment of Vice-Chancellors and composition of the Search-cum-Selection Committee.
